Implementation Guidelines for SDWARS/UCMR 

Volume I: Introduction to CDX and UCMR Submissions

EP001S2

EPA 816-R-01-022A

December 2001

iii

Contents

Chapter 1 Introduction ................................................................................1-1

CENTRAL DATA EXCHANGE IMPLEMENTATION GUIDE.....................................................1-1

SPECIAL CONSIDERATIONS AND OVERVIEW FOR UCMR ..................................................1-1

ORGANIZATION OF GUIDE.................................................................................................1-2

PURPOSE OF THIS VOLUME...............................................................................................1-3

RESPONSIBLE ENTITY .......................................................................................................1-3

HOW TO USE THIS VOLUME..............................................................................................1-4

Chapter 2 Central Data Exchange ................................................................2-1

BACKGROUND...................................................................................................................2-1

GOALS AND BENEFITS OF THE CDX..................................................................................2-3

Benefits to Reporting Facilities.................................................................................2-3

Benefits to EPA..........................................................................................................2-4

Benefits to the Public .................................................................................................2-5

WHAT THE CDX WILL DO WITH YOUR DATA..................................................................2-5

Chapter 3 Summary of UCMR Submission Options.....................................3-1

WEB SUBMISSION FLOW ...................................................................................................3-1

EDI SUBMISSION FLOW ....................................................................................................3-2

XML SUBMISSION FLOW..................................................................................................3-2

FLAT FILE SUBMISSION FLOW...........................................................................................3-3

Chapter 4 Implementation Considerations....................................................4-1

SYSTEM REQUIREMENTS...................................................................................................4-1

WHO SHOULD CONSIDER SUBMITTING DATA USING WEB FORMS?..................................4-2

WHO SHOULD CONSIDER SUBMITTING DATA USING XML?............................................4-3

Organizational Attributes...........................................................................................4-3

Requirements for Implementing XML......................................................................4-3

WHO SHOULD CONSIDER SUBMITTING DATA USING FLAT FILES? ..................................4-4

Organizational Attributes...........................................................................................4-4
iv

Requirements for Implementing a Flat File ...............................................................4-5

OTHER IMPLEMENTATION CONSIDERATIONS ....................................................................4-5

Chapter 5 Legal and Security Considerations ...............................................5-1

PINS AND PASSWORDS .....................................................................................................5-1

Security of PINs and Passwords ................................................................................5-1

Legal Considerations for PINs and Passwords..........................................................5-1

RECORD KEEPING .............................................................................................................5-2

BACKUP AND ARCHIVING CONSIDERATIONS.....................................................................5-2

Chapter 6 Electronic Reporting Registration ................................................6-1

WEB-BASED FORMS REGISTRATION.................................................................................6-1

Open Registration ......................................................................................................6-1

Pre-Registration .........................................................................................................6-3

Government Registration...........................................................................................6-4

PROCESSING THE REQUEST ...............................................................................................6-5

TELEPHONIC REGISTRATION .............................................................................................6-6

FACILITY UPDATE RESPONSIBILITIES................................................................................6-6

Appendix Abbreviations
Contents

v

FIGURES

Figure 1-1. PWS Online Data Review...................................................................................1-2

Figure 2-1. Foundation of CDX.............................................................................................2-1

Figure 3-1. Web Form Process ..............................................................................................3-2

Figure 3-2. CDX XML Process .............................................................................................3-3

Figure 3-3. UCMR Flat File Submission Process..................................................................3-4

Figure 4-1. Creation of an XML Document ..........................................................................4-4

Figure 6-1. Open Registration Process ..................................................................................6-3

Figure 6-2. Pre-Registration Process .....................................................................................6-4
vi
 1-1 

Chapter 1 

Introduction 

CENTRAL DATA EXCHANGE IMPLEMENTATION GUIDE

The U.S. Environmental Protection Agency’s (EPA) Central Data Exchange (CDX) 

is the single point of entry for most environmental compliance reporting. It 

accepts compliance reports in electronic and paper format. This implementation 

guide (IG) is designed to assist you with submitting data through the CDX. 

CDX is designed to support many EPA program areas and this IG covers standard 

CDX information. Some programs, however, have special requirements or may 

not require all the features or available functionality of CDX. Therefore, programspecific operations are distinguished at various points within this guideline. Subsequent volumes are more closely geared to program-specific implementations 

and issues. 

SPECIAL CONSIDERATIONS AND OVERVIEW FOR UCMR 

This four-volume IG is written specifically to assist laboratories, public water 

systems (PWSs), state environmental agencies, and other entities with electronically 

submitting and reviewing data for the Unregulated Contaminant Monitoring Rule 

(UCMR) program to CDX. Information passes through CDX to the Safe Drinking 

Water Accession and Review System (SDWARS), which is the information system 

that supports the collection of data for the UCMR. Preliminary analysis data are 

first entered by laboratories on behalf of the PWSs participating under UCMR. The 

PWS can then review their data online (see Figure 1-1). Once approved by the 

PWS, data are then available for state and EPA review before transmission to the 

National Contaminant Occurrence Database (NCOD). 
 

 1-2 

Figure 1-1. PWS Online Data Review 

ORGANIZATION OF GUIDE

This IG is the first volume of a five-volume set. This volume introduces the CDX 

and electronic reporting. The other volumes are listed below. 

◆ IG Volume II—describes completing and submitting web forms in detail. 

◆ IG Volume III—contains details about Electronic Data Interchange (EDI) 

in case EPA decides to exchange monitoring data using EDI (not 

applicable to UCMR). 

◆ IG Volume IV—documents in detail the formatting requirements for XML 

to be used with the EPA-provided document type definition (DTD) to 

create a well-formed, valid XML document. 

◆ IG Volume V—documents in detail the formatting requirements for a 

delimited flat file. 

Additional information about the CDX and submitting data is available from the 

following sources: 

◆ The publicly accessible EPA electronic commerce website at 

<http://www.epa.gov/cdx> 

◆ The CDX website at <http://epacdx.lmi.org> 

Laboratory

(Lab: Hold

data)

Public Water

System

(PWS: Hold

data)

State (State:

Hold data)

EPA

(EPA: Hold

data)

PWS:

Approve

data

Lab: Approve

data

PWS: Return data to

laboratory for corrections

SDWARS

(Delete Record)

PWS: Reject

data

NOTE: Data not approved by a PWS are

not visible to the state or U.S. EPA.

EPA's NCOD

NOTE: State may not Hold data for more than 90 days.

 After 90 days, the data are entered into NCOD.

NOTE: PWS:Approved data are viewable by EPA

even if the status is State:Hold.

State:

 Reviewed data
Introduction 

 1-3 

◆ The CDX technical support staff, at 1-888-890-1995 (8:00 a.m.–6:00 p.m. 

EST/EDT) 

◆ E-mail at <EPACDX@lmi.org> with “UCMR technical support” in the 

subject line. 

PURPOSE OF THIS VOLUME

This volume introduces you to CDX by answering the following kinds of 

questions:

◆ How do I register to submit electronically? 

◆ What sort of computer equipment do I need? 

◆ How do I know that the EPA received my data? 

◆ In what format do I send the data? 

You may send electronic data to the CDX using any of four methods: 

◆ Via a web form that you complete on your personal computer (PC) and 

transmit to the CDX via the Internet 

◆ Via an EDI transaction 

◆ Using Extensible Markup Language (XML) to transfer data to the CDX 

from a computer system at your site that maintains your data or 

◆ Via a flat file created using the provided format and transmitted to the 

CDX via the Internet. 

RESPONSIBLE ENTITY

These guides are published under the authority of 

Office of Environmental Information 

Information Collection Division 

Central Receiving Branch 

1200 Pennsylvania Ave, NW, Mail Stop 2823 

Washington, DC 20460 

The Office of Environmental Information (OEI) helps ensure that EPA collects 

high-quality environmental information and makes it available to the American 

public. OEI provides guidance to assist the agency about the way EPA collects, 

manages, analyzes, and provides or allows access to environmental information. 
 

 1-4 

Within OEI is the Office of Information Collection (OIC). The OIC is the agency 

lead for information collection programs, including how EPA obtains and manages 

information. OIC works closely with many partners, stakeholders, facilities, other 

federal agencies, and states. The Central Data Exchange within OIC is the EPA’s 

new infrastructure for supporting the exchange of environmental data between EPA 

and its external partners. Over the next several years, CDX will expand to become 

the point of entry for nearly all environmental data submissions to the agency. It 

will also improve collection, management, and sharing of environmental 

information among states, tribes, and EPA so they can achieve their respective and 

shared environmental goals. 

The CDX Technical Support desk will answer questions about using XML for 

data monitoring or compliance reporting. 

Support for electronic reporting is available via e-mail, fax, or telephone: 

◆ By telephone. Person-to-person telephone support is available between 

8:00 a.m. and 6:00 p.m. (EST/EDT) on our toll-free line at 1-888-890-1995. 

◆ By fax. You may request assistance 24 hours a day; support personnel will 

return calls between 8:00 a.m. and 6:00 p.m. (EST/EDT). Our fax number 

is 703-917-7105. 

◆ By e-mail. Send e-mail to <EPACDX@lmi.org> with “UCMR” in the 

subject line. Responses will be sent between 8:00 a.m. and 6:00 p.m. 

(EST/EDT). 

HOW TO USE THIS VOLUME

This volume will assist your understanding of the CDX electronic submission 

process. The other volumes of the IG explain how to submit data electronically. 

Volume I answers the following questions: 

◆ Chapter 2—Central Data Exchange 

 Why was the CDX started? 

 What are the goals and benefits of the CDX? 

 How does the CDX process data? 
Introduction 

 1-5 

◆ Chapter 3—Summary of UCMR Submission Options 

 What are my submission options? 

 What is the flow through CDX using web forms, EDI, XML, and flat 

files? 

◆ Chapter 4—Implementation Considerations 

 Who should consider submitting data using web forms? 

 Who should consider submitting data using XML? 

 Who should consider submitting data using flat files? 

◆ Chapter 5—Legal and Security Considerations 

 What are the legal considerations for an electronic signature? 

 What should I keep for electronic records? 

◆ Chapter 6—Electronic Reporting Registration 

 How do I register for electronic reporting? 

 Whom do I call if I have questions? 

 Does my facility have any responsibilities? 

The other volumes will assist you with submitting data electronically, provide 

step-by-step instructions for submitting data electronically, and tell you where to 

find additional information or assistance. If you still have questions about 

electronic reporting after reading this volume, contact either the OIC at the 

address above or the CDX Technical Support desk. 
 

 1-6 
 2-1 

Chapter 2 

Central Data Exchange 

This chapter answers the following questions: 

 Why was the CDX started? 

 What are the goals and benefits of the CDX? 

 How does the CDX process data? 

BACKGROUND

The CDX evolved from and is the culmination of several federal and EPA 

initiatives (see Figure 2-1). 

Figure 2-1. Foundation of CDX 

GPRA 1993

GPEA 1998

REI 1995

CSI 1994

I-3 1999

The federal and EPA initiatives shown in Figure 2-1 are described briefly below: 

 EPA Information Integration Initiative (I-3) of 1999. This initiative 

developed an integrated environmental database for data about public 

health and the environment. I-3 is based on principles of shared 

stewardship and multimedia information that is facility-wide and 

geographically oriented. Goals of I-3 include 

 improved environmental decision making at all levels; 

 reduced burden and transaction costs for all who provide and use 

environmental and public-health information; 

 greater certainty for regulated businesses; 

 more reliable and easier access for the public and improved 

performance for EPA; and 
 

 2-2 

 more accurate, reliable, and high-quality environmental data that will 

promote better public access and understanding, improved compliance, 

and greater accountability. 

 Government Paperwork Elimination Act of 1998 (GPEA). This law 

mandates that all federal agencies provide options to their stakeholders for 

conducting business electronically. The CDX meets this requirement and 

streamlines EPA’s data-collection procedures and information technology 

infrastructure. 

 EPA Reinventing Environmental Information (REI) Plan. This 1995 plan 

defined EPA’s strategy to work with states and industry to improve 

compliance reporting in four major areas: 

 Reducing the burden of reporting 

 Establishing electronic reporting 

 Better integrating of data across media programs 

 Improving public access. 

 EPA Common Sense Initiative (CSI). This initiative, which began in 1994, 

was a joint EPA, state, and industry study that produced several important 

ideas, including 

 using the Internet and World Wide Web as an information conduit, 

 establishing a single point of entry (previously “one-stop”) into EPA and 

state environmental agencies for compliance and other reporting, and 

 minimizing redundant data submitted by separating static facility data 

from recurring submissions and by standardizing and consolidating 

submission requirements. 

 Government Performance and Results Act of 1993 (GPRA). This law 

directs all federal agencies to put customer service standards in place, use 

customer feedback to measure how well they are performing against these 

standards, and report to the public about that performance. All federal 

agencies also are urged to make information more understandable and 

easily accessible. The CDX is EPA’s opportunity to better respond to the 

GPRA and the public’s desire for renewed trust and confidence in EPA’s 

ability to protect public health and safeguard the natural environment. 

The CDX is a common point for customer service, accelerated 

processing of collected data, and improved posting time for quicker 

public access. 

EPA’s establishment of the CDX and electronic reporting coincides with 

emerging trends in private industry. The number of electronic commerce (EC) and 

business-to-business (B2B) efforts have grown dramatically in the last few years. 
Central Data Exchange 

 2-3 

Current technologies, tools, standards, process reengineering practices, and 

favorable attitudes toward EC did not exist five years ago when EPA initiated its 

efforts toward electronic reporting using EDI. 

We are still on the technological edge of some aspects of electronic reporting, 

such as 

 a variety of digital signature technologies, each with different advantages 

and disadvantages, which are fairly expensive and complex to implement; 

 management and retrieval of electronic archives and records, which tend 

to vary by originating application and operating system, that become 

difficult to retrieve over time as applications evolve; and 

 various hardware, operating systems, and configurations of commercial 

Internet browsers, which entail complex connections and pose interoperability challenges. 

EPA is working with all stakeholders to collect input and pursue effective 

solutions to these challenges. 

GOALS AND BENEFITS OF THE CDX 

The CDX meets the EPA and federal mandates by establishing the following 

goals: 

 Improving environmental data quality 

 Reducing burden on all stakeholders 

 Reducing processing delays and improving public access 

 Integrating data across systems 

 Improving data security and distribution capacity. 

As it attains these goals, the CDX will benefit all types of stakeholders who 

choose to participate in submitting data electronically. 

Benefits to Reporting Facilities 

The CDX collects compliance and some sampling data from a variety of facilities, 

from small commercial firms to the largest companies in the country. Reporters 

include government installations, Indian tribes, and other special groups. Electronic 

reporting will be voluntary for all of the established compliance-reporting program 

stakeholders and may be mandatory for new initiatives. Therefore, the CDX must 

provide suitable reasons for moving from well-established paper processes. Some 
 

 2-4 

of the benefits to reporters of electronic reporting provided by the CDX are the 

following: 

 Flexibility to support manual entry of data through web forms or machineto-machine transfers using EDI, XML, or flat files 

 A single point of entry for submissions and standard processes and 

formats across media programs and compliance forms 

 One call for assistance 

 Web forms that will simplify entry by containing substantial data edits and 

prepopulation of known data where appropriate (e.g., facility number, 

address, and permit number) 

 Immediate receipt acknowledgement and (depending on the report) an 

official copy of record 

 Elimination of the costs and delays of preparing, reproducing, mailing, 

storing, and other processing of paper forms 

 Streamlined EPA and state processing so reporting facilities will be more 

confident that their data will be processed efficiently and accurately—

providing a quicker and more accurate posting of their data for the public 

and demonstrating that the facility is environmentally compliant 

 Encouragement for facilities to automate and reengineer their processes 

for collecting compliance data so they can forward data to EPA 

automatically—further reducing the cost of compliance reporting. 

Benefits to EPA 

Electronic reporting and implementation of CDX will significantly benefit EPA: 

 The system will eliminate the cost of entering data into information 

systems and correcting the associated errors. 

 CDX will eliminate costs and delays inherent in receiving, processing, and 

storing paper forms. 

 CDX will establish a single organization for helping receive, archive, 

secure, and distribute data. The CDX will increase substantially the 

economies of scale by discouraging the establishment of multiple and 

diverse versions for different national programs. 

 The CDX will increase the capability for transforming (manipulating) data 

formats and exchanging data with other government organizations, 

including state environmental agencies. 
Central Data Exchange 

 2-5 

 Indirectly, electronic reporting will foster an environment in which EPA 

can 

 apply newer IT tools 

 data warehousing, and 

 data mining, online analytical processing (OLAP), and other query 

and presentation techniques to improve analysis of data; 

 implement other data goals 

 developing a single, up-to-date database for sharing facility 

information with all program areas, 

 improving the standardization of data elements, and 

 consolidating and integrating reporting requirements. 

Benefits to the Public 

The public will benefit from all of the foregoing changes. Users of public 

environmental data will notice better uniformity and accuracy in reported data, 

more timely posting of reports to databases, and better presentation of data 

through tools that will improve everyone’s ability to query, manipulate, 

understand, and display meaningful environmental data. 

WHAT THE CDX WILL DO WITH YOUR DATA

CDX will not replace existing EPA program area databases. It will, however, be 

the single point of entry and perform the following important functions: 

 Time- and date-stamp each submission and electronically acknowledge the 

receipt of the data. 

 Scan for viruses and provide a firewall to reduce the risk of attack. 

 Archive all incoming transactions. 

 Verify the submitter’s facility data. 

 Authenticate (where needed) the submitter’s digital signature. 

 Perform limited data edit checks. 

 Convert data from the inputted format to a format acceptable by the 

receiving EPA or government system. 

 Forward data to the receiving system. 
 

 2-6 

After you have obtained a password and identification number through the 

registration process, you may log on to the CDX website. Data flows differently 

for machine-to-machine transfers and web submissions. Each program may have 

slightly different variations based on their requirements for signatures, certifications, 

and legal purposes. This section discusses the general flow; specific program flows 

are discussed in the other volumes of the IG. 

Regardless of the submission type, the CDX has an extensive transaction log and 

error-messaging system. The CDX places every function, successful or not, into 

the transaction log, along with the date and time, result, and associated messages. 

The log stores these actions only. The actual data in the submission are stored in 

archives at various instances during processing. 

The CDX distributes two types of messages—positive and error. The positive 

messages that you can expect are the acknowledgment of receipt of the data and 

the official copy of record (depending on the program requirements). If generated 

from the program, both are sent to your CDX mailbox. The error messages that may 

be generated during data processing include virus errors, security or signaturerejection messages, or translation errors. All of these messages are sent to you by 

e-mail. A notification message of error is sent to the system administrator to assist 

in correcting the problem. 
 3-1 

Chapter 3 

Summary of UCMR Submission Options 

This chapter answers the following questions: 

◆ What are my submission options? 

◆ What is the flow through CDX using web forms, EDI, XML, and flat 

files? 

The CDX supports a number of electronic reporting options. These options give 

all reporting organizations flexibility, regardless of size. You should evaluate the 

options and decide which best fits your organization’s information technology 

capabilities and business strategies, as well as what is most convenient. Because 

technology evolves, EPA will continue to test and evaluate new EC procedures, 

hardware, and software. 

CDX operations will have to balance diverse user desires for formats, 

technologies, and methods that meet current business practices with the need to 

manage costs and avoid inefficiencies that may result from undue complexity. 

The following sections describe the CDX’s current capabilities for receiving data 

from users. 

The following sections and similar sections in Chapter 4 are primarily intended 

for laboratories, as only they will have a choice as to how to enter analytical data 

into the SDWARS database. PWS, state agencies, and other entities may only use 

web forms to access and change status of SDWARS data. 

WEB SUBMISSION FLOW

When you log onto the CDX website, the CDX will verify your ID and password. 

Select which program you would like to access. For UCMR, you may choose to 

access SDWARS or a file upload link. 

Initially, you will need to verify PWS, facility, and sampling point data and 

ensure that client lists and points of contact are correct (see Figure 3-1). Once this 

is done, you may perform recurring activities for processing a sample (see bottom 

half of Figure 3-1). 
 

 3-2 

Figure 3-1. Web Form Process 

PWS: 

* Establish inventory data

* Define contacts

Establish and 

maintain 

inventory data

Lab:

1. Creates batch

2. Enters sample

3. Associates sample with batch

4. Enters analyte result

5. Approves data

PWS:

1. Reviews data approved by lab 

2. Approves, holds, rejects, or

returns data to lab

State/Region/Federal:

Reviews data approved by PWS

Recurring 

processing 

of sample data

Data marked “return to lab”

Lab edits data

Data moved to EPA

Approved data

Approved data

Lab:

* Establish client PWSs 

* Define contacts

* Verify inventory data

Four web forms relate to the submission of UCMR data. The first web form 

records a batch and its quality control data. The second logs in samples. On this 

form, you will record the PWS, facility, sampling point, sample ID, and collection 

date. The third web form associates the sample to a batch. The forth web form 

captures the analytical results drawn from the sample’s associated batch. 

After your laboratory has entered data into each form, you can review the data. 

Once approved, the data are placed into SDWARS for the PWS to review. 

EDI SUBMISSION FLOW

EDI will not be used for UCMR submissions. 

XML SUBMISSION FLOW

XML submissions must comply with the appropriate DTD or XML schema. A 

copy of the latest XML DTD or schema is available from the CDX website. Your 

laboratory may create an XML submission by extracting data from your 

Laboratory Information Management System (LIMS). The various LIMSs may be 

programmed to extract and parse the XML document or you may use data 

transformation software to parse the data once extracted. 

Your laboratory will submit data in XML to the CDX via the web (see Figure 3-2). 

The submission is scanned for viruses as it comes through the firewall. After 

successfully scanning the submission, the CDX sends a notification of receipt 

to your “MyCDX” inbox. 
Summary of UCMR Submission Options 

 3-3 

The data are then archived in the original submission format. At this point, CDX 

will look into the data to determine their form. Because the data are not signed, 

they are placed into the staging server for parsing into SDWARS. 

Figure 3-2. CDX XML Process 

Lab LIMS

Lab File

Conversion

Internet

(SSL)

System

Dependant

Format

XML

(UCMR)

CDX Server

Safe Drinking Water

Accession & Review

System (SDWARS)

Yes

 MyCDX Inbox

File Name and

Authorized

Sender?

Format

 and Data

Validation

Successful File

Upload Message

No: Error Message

XML

(UCMR)

Receipt

 Acknowledgement

No: Error Message

User logs in to verify data, change

status, and override range checks.

FLAT FILE SUBMISSION FLOW

The first step to creating a flat file is to prepare the extraction of the data from 

your LIMS. Depending on the LIMS your laboratory uses, you may either 

program the LIMS to extract and parse the flat file elements or use data 

transformation software to parse the data once extracted. 

The data must be parsed into the compliant flat file format. EPA maintains the 

most recent UCMR flat file format on the CDX website. You should validate the 

resulting flat file to ensure it complies with the structure of the format. 

CDX will poll a mailbox on the CDX server and convert the flat files to the 

UCMR XML document (see IG Volume IV for a description of XML). The XML 

document is then sent to the CDX parser for validating and uploading into 

SDWARS. Figure 3-3 represents the processing of a UCMR flat file submission. 
 

 3-4 

Figure 3-3. UCMR Flat File Submission Process 

Lab LIMS

Lab File

Conversion

Internet

(SSL)

System

Dependant

Format

Flat File

(UCMR)

CDX Server

Safe Drinking Water

Accession & Review

System (SDWARS)

Yes

 MyCDX Inbox

File Name and

Authorized

Sender?

Translation

to XML and Data

Validation

Successful File

Upload Message

No: Error Message

Flat File

(UCMR)

Receipt

 Acknowledgement

No: Error Message

User logs in to verify data, change

status, and override range checks.
 4-1 

Chapter 4 

Implementation Considerations 

This chapter answers the following questions: 

◆ Who should consider submitting data using web forms? 

◆ Who should consider submitting data using XML? 

◆ Who should consider submitting data using flat files? 

Regardless of the submission method you choose, you must consider resource 

requirements. You should especially consider knowledge resources (i.e., 

personnel and training), hardware and software, and business strategies. This 

guide is not meant to be the evaluation tool for your organization; however, it 

does highlight some areas that you should consider. 

Knowledge resources are your personnel resources and the amount of training 

required to develop and maintain the business system you choose for your 

reporting. For instance, you may choose to report via the web form and keep 

paper files, or you may choose to keep all your files electronically. For the former 

option, you must ensure you have appropriate storage space; for the latter, you 

must appropriately train your personnel to use the electronic equipment. 

Electronic reporting is evolving. To participate effectively, you must have 

appropriate computer hardware and software, which must be updated and 

maintained periodically. Electronic reporting also should be a natural extension of 

your organization’s overall information technology (IT) strategies. Electronic 

reporting should be a convenient method for reporting required data to EPA; it 

should not introduce any additional burden. 

This chapter will help guide you in determining which submission method would 

work best for you. 

SYSTEM REQUIREMENTS

To access CDX and SDWARS you will need the following: 

◆ Personal computer with a 486 processor or better; Pentium or above is 

recommended 

◆ One of the following versions of the Microsoft Windows operating 

system: Windows 95BY2K Service pack installed (Original Equipment 

Manufacturer Service Release 2); Windows 98; Windows NT3.0 (Service 

Pack 5); or Windows 2000 
 

 4-2 

◆ Web browser: either Internet Explorer 5.0 or higher with 128-bit encryption 

◆ Internet access. 

To determine whether you have the Y2K upgrade installed in a Windows 95 or 98 

environment, check for the presence of the Y2KW95.txt file in the Windows 

folder, 

◆ Go to Windows Explorer, select View, then click on Details. 

◆ Look in C:\Windows to find Y2KW95.txt file. 

To determine whether you have the Y2K upgrade installed in a Windows NT 

environment, check for the presence of the Y2KW95.txt file in the Winnt folder, 

◆ Go to Windows Explorer, select View, then click on Details. 

◆ Look in C:\Winnt to find Y2KW95.txt file. 

Call the CDX Technical Support line for assistance and more information at 

1-888-890-1995. 

While CDX and SDWARS software can operate with 486 processors and low 

speed Internet connections, increasing your processor speed, amount of RAM, 

and the speed of your Internet connection will definitely improve response times. 

WHO SHOULD CONSIDER SUBMITTING DATA USING 

WEB FORMS? 

Completing the form electronically is easier than dealing with paper. However, it 

is time consuming to gather the data and enter them into the SDWARS web 

pages. If you have a lot of data to enter and an automated system for storage 

(e.g., the Laboratory Information Management System [LIMS]), you should 

compare the cost of setting up a flat file or XML submission to the cost (i.e., time) 

of entering the data into the web forms. If you do not have a lot of data to enter or 

you do not have the capability or technical expertise to implement flat files or 

XML, then entering data via the web forms may be your best option. 
Implementation Considerations 

 4-3 

WHO SHOULD CONSIDER SUBMITTING DATA 

USING XML? 

Organizational Attributes 

Because of the complexity of XML implementation, an organization should 

possess at least one of the following attributes: 

◆ The organization should have IT competency. The organization need not be 

large or have a large IT staff. Many small companies are very successful at 

implementing an appropriately sized XML solution. However, you must 

have staff members who can integrate the different components XML 

requires. 

◆ The organization should have sufficient electronic traffic. This traffic need 

not be in reporting data to SDWARS exclusively. The electronic traffic 

may include other EPA (or state) reports or other XML exchanges, such as 

procurement, transportation, or inventory management. The organization’s 

XML resources may be in another division or facility. 

◆ The organization should have a substantial environmental reporting 

obligation. This obligation may require submitting multiple reports 

(forms); for the UCMR, it may entail reporting a large number of samples 

that might contain highly sensitive contaminants. Regardless of the nature 

of the obligation, it must be sufficient so the organization is willing to 

invest resources in collecting and managing environmental data. 

Requirements for Implementing XML 

If your organization has the foregoing attributes or is migrating toward them, you 

should consider implementing XML. XML systems can be operated at any system 

level, from PCs to servers to mainframes. The requirements for operating an XML 

system can vary dramatically; the list below represents only an overview: 

◆ An application system containing monitoring data (this system can be a 

spreadsheet, environmental management software, or a large-scale 

database system) 

◆ Document type definition (DTD), which defines the rules the XML 

document must follow to be valid (provided by EPA) 

◆ Validating XML parser to map the extracted data with the DTD. 

Commercial XML parsers are available in a variety of these packages and 

range in capabilities and cost, from free to thousands of dollars. 
 

 4-4 

◆ Telecommunications capability for the translator to access either the 

Internet, dial-up connections to EPA, or a value-added network 

◆ An IT system (e.g., printers, backup systems) and staff infrastructure 

(e.g., the ability to program and manage archive and related systems) to 

support EC operations 

◆ A PC system that is connected to EPA’s CDX web environment. This 

connection is required because all UCMR forms will be submitted to the 

CDX for authentication of transmission and proper routing to SDWARS. 

Once the XML parser maps the data with the DTD, a valid XML document can be 

formed. Figure 4-1 is an overview of an XML environment. 

Figure 4-1. Creation of an XML Document 

Extracted data

from database

Validating Parser

DTD

XML

Document

WHO SHOULD CONSIDER SUBMITTING DATA 

USING FLAT FILES? 

Organizational Attributes 

Because flat files are similar to XML but less complex, organizations considering 

submitting data in this method should possess attributes similar to those discussed 

in the previous section: 

◆ The organization should have IT competency. The organization need not 

be large or have a large IT staff. Many small companies are very 

successful at implementing a solution. However, you must have staff 

members who can integrate the different components that extract or 

generate a flat file from your lab’s system. 
Implementation Considerations 

 4-5 

◆ The organization should have sufficient electronic traffic. If you are 

submitting a large volume of files regularly, creating the file and 

maintaining the file format may be worth the time and effort in case the 

format changes. On the other hand, if the organization only submits a 

couple of records a month, entering the data in the web form may be more 

efficient. 

Requirements for Implementing a Flat File 

If your organization has the foregoing attributes, you should consider submitting 

flat files. The requirements for submitting a flat file include the following: 

◆ Knowledge of your laboratory information system’s architecture 

◆ Process for extracting data from your laboratory system into a flat file. 

OTHER IMPLEMENTATION CONSIDERATIONS

In addition to reviewing your IT capabilities and business practices to determine 

whether to use web forms or implement XML or flat files, you should review two 

administrative aspects. To electronically submit data for UCMR, your organization 

must register an official and other representative company personnel who will enter 

data into the web form with the EPA’s CDX. Moreover, you must continually 

update the information as personnel change. Similarly, you must keep your facility 

information current through the appropriate EPA offices. 
 

 4-6 
 5-1 

Chapter 5 

Legal and Security Considerations 

This chapter answers the following questions: 

◆ What are the legal considerations for an electronic signature? 

◆ What should I keep for electronic records? 

This chapter focuses specifically on considerations for electronic reporting. 

PINS AND PASSWORDS

Security of PINs and Passwords 

The CDX issues personal identification numbers (PINs) and passwords during the 

registration process for access to the CDX website. You are responsible for 

maintaining the integrity of your user ID and PIN or password. Transactions 

made with your PIN or password are considered approved and submitted by you. 

If you believe that your PIN or password has been compromised, notify the CDX 

technical support staff immediately. 

Legal Considerations for PINs and Passwords 

For forms that rely solely on a user ID, password, or PIN, EPA defines a 

“signature” as the filer’s typed name in the form. This signature is part of the 

document. Your ID, password, or PIN validates your identity but is not part of the 

document. The Federal Communications Commission (FCC) also uses this 

approach for certain filings. In Report and Order on Electronic Filing of 

Documents in Rulemaking Proceedings, the FCC states that 

a signature will be considered any symbol executed or adopted by the 

party with the intent that such symbol be a signature, including symbols 

formed by computer-generated electronic impulses.1

Degrees of risk are associated with how an agency disseminates a PIN or 

password to a submitter. EPA requires that it knows who is logged onto the 

system at all times (EPA Directive 2100, Information Resources Management 

Policy Manual). The CDX will apply your user name and password on line for 

each filing; a confirmation will be sent electronically to the e-mail address 

 1

 FCC, General Council Docket Number 97-113, p. 23. 
 

 5-2 

submitted by you in your “MyCDX” organization information. Your name and 

password will validate you. 

RECORD KEEPING

EPA recommends that you keep a copy of all transactions (including the time and 

date) sent to and received from EPA, or keep copies in accordance with your 

organization’s policies and procedures. These transactions may include 

submissions, receipt acknowledgments, error messages, resubmissions, and 

transmissions from the UCMR program area. 

The saved copies are your audit trail for submissions to EPA. The original 

submission is maintained at the CDX as an official copy of record; the data are 

maintained by SDWARS. 

Submitters may maintain electronic or paper audit copies. As a submitter, you 

should maintain copies of your UCMR data to generate an audit trail. The audit 

trail may include the following: 

◆ Date and time of each submission 

◆ Receipt acknowledgment (which contains the CDX tracking number) 

◆ Error messages (e.g., virus, failed transmissions, failed translations) 

◆ Error corrections and resubmissions 

◆ Correspondence with SDWARS. 

BACKUP AND ARCHIVING CONSIDERATIONS

The UCMR does not require you to keep these documents; however, it is common 

business practice to back up and archive your electronic data in case the system 

fails. As technology progresses and you upgrade, you may want to consider 

backward compatibility for document retrieval. You also should consider keeping 

more than one copy as a backup in case the hardware or software fails, viruses 

attack, or other technological anomalies occur. 
 6-1 

Chapter 6 

Electronic Reporting Registration 

This chapter answers the following questions: 

◆ How do I register for electronic reporting? 

◆ Whom do I call if I have questions? 

◆ Does my facility have any responsibilities? 

All users that participate in electronic reporting—whether by web, flat file, or 

XML—must register with CDX. The registration information gives EPA an 

update and provides some of the general information required to pre-populate 

your submissions. 

This chapter summarizes the process you must follow to access the CDX and to 

acquire a certificate, if needed, to sign forms. CDX registration has four objectives: 

◆ Associate a logon ID and password to every user of CDX. 

◆ Validate the personal and corporate information of each user. 

◆ Determine the program areas of interest for each user so access to these 

applications can be granted. 

◆ Provide access to digital certificates for users who require them. 

CDX will offer two methods for registration—telephonic or through web-based 

forms. To facilitate registration, CDX also offers separate registration websites to 

government (e.g., states, regions, local governments) and non-government (e.g., 

PWSs, laboratories, companies) stakeholders. 

WEB-BASED FORMS REGISTRATION

Web-based forms are the preferred means of registering users of CDX. There are 

two options in the web-based approach: open and pre-registered. 

Open Registration 

Open registration forms are for individuals who want to participate in electronic 

exchanges with the EPA CDX but did not or have not received a letter of 

invitation. The registrant may have learned about CDX from a number of sources, 

such as Federal Registry notices or industry association newsletters or forums. 
 

 6-2 

NOTE: Government registrations cannot be requested through open registration. 

See the section on government registration following instructions for pre-registration. 

To use the open registration web form 

◆ connect to the Internet via a secure socket layer– (SSL-) protected session 

to the CDX and accept the EPA terms and conditions for using CDX, 

◆ select a user ID and password, 

◆ provide a question and answer for authentication purposes, 

◆ provide personal and corporate information (e.g., postal address, phone 

numbers, e-mail address), 

◆ indicate which EPA program applications you want to participate in, and 

◆ select the role and the associated program ID and method of submission 

for that role.1

When you apply, the EPA program is notified of the request. If a legal or 

procedural reason exists for denying electronic reporting rights, the EPA program 

may direct CDX to terminate your access privileges. 

Some EPA programs may require you, the registrant, to mail in a sponsor letter. 

The sponsor letter is a business letter from your organization to EPA informing 

EPA that you are authorized to interact with the CDX on behalf of the 

organization. You will not be able to perform activities in the desired program 

area for the organization indicated by the client ID until the sponsor letter is 

processed through CDX. 

Figure 6-1 shows the open registration process. 

 1

 The program ID for the public water systems (PWSs) is the PWS ID number—a twocharacter postal state code followed by seven digits assigned by the state. To find a PWS ID 

number, contact the state. For laboratories, the EPA lab ID number is a two-character postal state 

code followed by five digits assigned by EPA. To find a lab ID number, contact the Safe 

Drinking Water Hotline at 1-800-426-4791. 
Electronic Reporting Registration 

 6-3 

Figure 6-1. Open Registration Process 

Submitter

Log-on

SSL Register? Yes CDXHomepage

Enter desired

user ID and

password

CA conducts ID proofing

 (May take up to 3 days)

Certificate

issued?

CA

Accept

terms and

conditions

Provide

authentication

question and

answer

Role

information

Organization

information

Valid user

ID and

password?

Certificate

required?

MyCDX

No

Yes

No

Request

additional

roles?

Sponsor letter

required?

Yes

No

Yes

No

No

Log-on

via SSL

to request

certificate via

Web site

Yes

No

Yes

Generate sponsor letter on

organization's letterhead and

have organization official sign

Mail sponsor

letter to EPA Yes

No

Pre-Registration 

Pre-registration reduces the burden for the submitter by pre-populating web 

forms with data from EPA data sources. Figure 6-2 illustrates the preregistration process. 

To use the pre-registration process, the registrant will 

◆ receive an invitation letter, which contains a formal invitation to 

participate in electronic reporting; a uniform resource locator (URL); and 

a customer retrieval key (CRK). CRKs are valid for one-time use and then 

are eliminated from CDX registration. (The letter also will contain the 

EPA’s terms and conditions for using the CDX for electronic compliance 

reporting.); 

◆ log-on to CDX using the URL and the customer retrieval key; and 

◆ approve or modify the data in the pre-populated forms to ensure accuracy. 

(If data are not provided from EPA data sources, the user must provide 

them just like in open registration.) 
 

 6-4 

Figure 6-2. Pre-Registration Process 

Customer

Retrieval Key

(CRK)

Submitter

Log-on

SSL

Valid

CRK? Yes

CDX preregistration

screen

CDX

Enter desired

user ID and

password

CA conducts ID proofing

 (May take up to 3 days)

Certificate

issued?

CA

Accept

terms and

conditions

CDX

Homepage

Provide

authentication

question and

answer

Role

information

Organization

information

Valid user

ID and

password?

Request

additional

roles?

Certificate

required?

MyCDX

Log-on via

SSL to request

certificate

via Web site

No

No

Yes

No

No

Yes

Program Area requests CDX to

send letter of invitation to the

Stakeholder.

No Yes

Sponsor letter

required?

Generate sponsor letter on

organization's letterhead and

have organization official sign

Mail sponsor

letter to EPA

No

Yes

Yes

No

Yes

Some EPA programs may require you, the registrant, to mail in a sponsor letter. 

The sponsor letter is a business letter from your organization to EPA informing 

EPA that the registrant is authorized to interact with the CDX on behalf of the 

organization. You will not be able to perform activities in the desired program 

area for the organization indicated by the client ID until the sponsor letter is 

processed through CDX. 

Government Registration 

Registering government users is a subset of the pre-registration process. As a 

government registrant you access the CDX registration through a web page 

reserved specifically for government users. The government registration process 

will present government roles only to registrants who enter through this unique 

portal. The basic sequence of registration parallels that of pre-registration, except 

government users will not be required to submit a sponsor letter. 

When you complete the government registration, you will have the option to 

nominate other government employees for participation in electronic reporting. 

The nomination option currently is unique to government registration—it is not 
Electronic Reporting Registration 

 6-5 

offered to other CDX registrants. After experience is gained with the notion of 

nomination, this privilege may be extended to the public registrants. 

PROCESSING THE REQUEST

When you complete the online registration, the CDX activates a CDX account for 

you based upon the user ID and password you provided. You are notified that the 

CDX account is activated through two mechanisms: an e-mail to the e-mail 

address provided during registration and an e-mail to your “MyCDX” inbox. For 

programs that have no additional registration requirements, your “MyCDX” 

display also will contain a URL for the EPA program for which you just 

registered. The URL allows you to link directly to the CDX application for that 

EPA program directly from your “MyCDX” display. 

Access to EPA programs that require additional documentation (e.g., sponsor 

letter) will only be granted after CDX has received the documentation. Once it is 

received, your registration status for that EPA program application is set to active. 

This triggers an e-mail notifying you that your status has changed, and ensures 

your “MyCDX” display contains the URL link to the EPA program application. 

The e-mail notification of the active status is sent to an OEI Lotus Notes database 

and to the EPA program point of contact (if desired), as well. 

Some EPA programs supported by CDX may require a digital certificate for 

activities like SSL mutual authentication or digital signatures. If you register for 

one of these programs, a voucher number and a URL that links to the certificate 

authority’s (CA’s) website will be sent to you. The voucher number indicates 

you are approved to apply for a certificate using the procedures defined under 

GSA’s ACES2

 program. 

You will receive a certificate within 3–5 days, after the CA completes the identity 

proofing. Once the CA validates your identity, the CA notifies you that your 

certificate is available to download. After downloading the certificate, you will 

have the authority to digitally sign documents. 

Registered users will be able to participate in different EPA programs by modifying 

their registration profile to indicate their interest in reporting electronically to EPA 

programs as they are added. You also can modify your data to un-enroll from 

electronic reporting (either completely or by individual EPA program). 

EPA also will require you to revalidate the registration data biannually to 

ensure all information remains current. 

 2

 Access Certificates for Electronic Services, a federally charted public key infrastructure 

sponsored by the General Services Administration. 
 

 6-6 

TELEPHONIC REGISTRATION

The telephonic registration is intended to accommodate individuals with 

disabilities who may require additional assistance to complete the forms. To 

register using this method 

◆ call the technical support staff and 

◆ provide the information required to complete the web form. 

The telephonic registration process is expected to be a low volume operation.

FACILITY UPDATE RESPONSIBILITIES

You are responsible for maintaining the correct contact and facility information 

through your region or primacy state agency for updates to the SDWARS. You 

will be required to verify your current facility information for the initial 

registration. After the initial update, you will also be required to review your 

information periodically and notify EPA of any changes in order to update the 

SDWARS. 
A-1

Appendix

Abbreviations

ACES Access Certificates for Electronic Services

B2B business-to-business

CA certifying agent

CDX Central Data Exchange

CRK customer retrieval key

CSI Common Sense Initiative

DTD document-type definition

EC electronic commerce

EDI Electronic Data Exchange

EPA U.S. Environmental Protection Agency

FCC Federal Communications Commission

GPEA Government Paperwork Elimination Act

GPRA Government Performance and Results Act

GSA General Services Administration

I-3 Information Integration Initiative

ID identification

IG implementation guide

IT information technology

LIMS Laboratory Information Management Guide

NCOD National Contaminant Occurance Database

OEI Office of Environmental Information

OGWDW Office of Ground Water and Drinking Water

OIC Office of Information Collection

OLAP online analytical processing

PE performance evaluation

PIN personal identification number

PC personal computer

PWS public water systems
A-2

REI Reinventing Environmental Information

SDWARS Safe Drinking Water Accession and Review System

SSL secure socket layer

UCMR Unregulated Contaminant Monitoring Rule

URL uniform resource locator

XML Extensible Markup Language

Y2K Year 2000
Office of Water (4601)

Washington, DC 20460

EPA 816-R-01-022A

www.epa.gov/safewater

December 2001